Member Since: 22nd Apr 1999
23rd Oct 2012
Consider the implications beyond this case
This is a little like the situation that has arisen that many people (notably solicitors) will not give employee references.
In this particular case I can see no problem in saying that "we have no suspicions of money laundering".
However, in another case where a report had been made, it would be tipping off to say so. Say the request had come from the same successor firm and you failed to reply in that case. The successor firm might draw their own conclusions. They would have been tipped off as a result of your inconsistent behaviour.
I will leave it to David Winch to comment on how your defence of lack of intent would fair in a criminal court.
It would seem that the safe option is therefore to act consistently in all cases and state something like "it is not the policy of this firm to comment on money laundering issues".
12th May 2011
Highlighting before today
As others have said but could use =today() instead of =now()
If your dates were not pure dates but included times as well would make a difference
3rd Nov 2003
Money laundering question
If anyone replies positively to question 14 of the sample letter from Phil Rees will they not have committed the offence of "tipping off" ?
28th Feb 2003
A interesting question. In some circumstances I would not undervalue the simple Excel spreadsheet. Are these control lists kept up to date by you or by staff? How many clients do they need to handle? Is the same information recorded in more than one place? Are you trying to incorporate a time ledger function - if so what do you do at the moment?
Interested to know about Stephen's solution.
29th Nov 2002
The information re account numbers is very useful.
However a further problem seems to be split entries which are merely reported as SPLIT